The Niagara Heritage Partnership strongly
endorses Alternative 3 for the National Heritage Area and a Federal
Commission for a management entity.

Requested Rationale

Although we acknowledge an impulse to restrict
the Heritage Area to Niagara Falls because of the area’s desperate need
for environmental and economical revitalization, we chose Alternative 3 in
recognition of our region’s need to tell our entire cultural, historical,
and natural stories in context and with integrity.

We chose a Federal Commission because of our
admiration, generally, of the respect the National Park Service has for
the natural environment, which is reflected in the attitudes of its
employees who come in contact with the public, in its preservation
activities, and in its educational programs.

The Niagara Greenway Commission, seemingly
favored by the Niagara National Heritage Area study report, would be the
worst possible choice for a management entity. It’s a subset of the NYS
Office of Parks, Recreation and Historic Preservation (OPRHP) which, given
their dismal record of stewardship on the Niagara Frontier, should
disqualify either of these entities from any function serving the natural
environment and multi-cultural indigenous and visiting populations.

It would take, literally, hundreds of pages, a
book, to document and detail the lack of stewardship displayed by OPRHP on
the Frontier, regardless of what may otherwise be their brilliant
performance in other state parks, so outstanding that Commissioner Castro
has received award recognition.

At Niagara, in broad strokes:

- OPRHP has
contracted with a private concessionaire, Delaware North, who engages

along Lower Niagara River.” This is OPRHP
endorsing Olmsted out of one corner of

their agency mouth and advocating
contradictory practices out of the other corner.

- There is no
“specific need” for this unless OPRHP has retained and repaved closed

parkway lanes as another potential money-maker
for State Parks, to further degrade and

prevent the restoration of natural landscapes,
and to further deny opportunities for local

businesses (tour drivers, etc.), with the
parkway gone to access points of interest along

the lower river by right angle routes. Several
years ago, we (NHP) were given

assurances in writing that State Parks had no
plans for such an enterprise. Evidently,

they’ve made such plans since then.

- OPRHP seems to
think generating revenue is their chief function; is stewardship on the

list at all?

For nearly a half-century, those of us who
value a natural Niagara in our parks have seen Olmsted’s vision steadily
eroded by ignorance and commercial interests, but never so rapid an
erosion as has occurred under the present administration. Over the years,
many of us have been publicly critical of anti-Olmsted practices, saying
that our parks were being turned into carnival grounds or a circus. We
intended these comments as cautionary insults, but OPRHP has evidently
mistaken them as advice. This past year has seen the parks infested with
people prancing around in yellow bear suits or being zipped around in
electric carts, food shacks, coin-squeezing souvenir stations, chainsaw
sculpture contests, huge kite flying events, and an elephant.

Delaware North, though not alone, is in the
middle of all this and resentful of the possibility of a Federal
Commission as a management entity—hence the petulant questions from the
Delaware North rep at the Heritage Area hearing about whether “the law
could be changed” so we could get Federal millions and expertise, but no
Federal oversight or participation. Perish the thought. Federal presence
and a new more thoughtful OPRHP, coming soon we trust, might stop, or at
least slow, the erosion.

Unfortunately, the Greenway Commission will
probably remain intact. With minimal exception, the locally appointed
Commissioners are sufficiently out of touch with their mission (“parks…in
the Olmsted tradition” p.16) that two of them agreed on a recent call-in
television show, (Insight, LCTV, 8 December 2005) that they’d consider
locating a “saw-sharpening industry” on the waterfront if approached with
such a request. (Several months ago, we (NHP) emailed the Olmsted plan to
each of these Commissioners.) One of those on the television show, in
response to the idea that the demographics of the Commission didn’t
adequately represent our multi-cultural region, implied the Commission
would be qualified to be Heritage Area managers fully able to present
Native American and African American heritage because of the proximity of
his village to the 2,000 year-old Indian mound, and the Tuscarora Nation
reservation, and because of the “plays and musicals” about black history
performed in the Village. Is anyone paying attention to this outrageous
nonsense?

OPRHP’s most recent preposterous announcement
is their intention to shut off the flow of water over the American Falls
for up to a year. This is necessary, they claim, to replace, not restore,
the pedestrian bridge to Goat Island, which has deteriorated beyond
repair. The stone bridge, over a hundred years old, was designed by
Frederick Law Olmsted (built in 1901). (We note that damage to the bridge
leading to its current condition may have been caused by OPRHP in the
first place by allowing inappropriate use of the bridge during the
“remodeling” of the larger vehicle bridge up rapids.)

In any case, the flow of water over the
American Falls a century ago was nearly double what it is now. The
stonemasons and others who build the Olmsted bridge in 1901 did not find
it necessary to stop the water from flowing over the American Falls to do
so.

As reported in a recent newspaper article, the
current OPRHP shut-off plan will result in large amounts of diverted and
backed up water being shared by Canadian power generating facilities and
by NYPA. Will these water amounts be in excess of the gallonage now
permitted by International Joint Treaty?

If so we have questions: In whose pockets will
the extra money made by sale of electricity end up? Will OPRHP use
greenway funding provided by NYPA to pay for damming and bridge
replacement? Will it be done from the separate fund NYPA has already
agreed to provide OPRHP as their “greenway” settlement or from additional
funds to be allocated to OPRHP to satisfy plans the Niagara Greenway
Commission will eventually complete and submit to OPRHP for
implementation? What will be the difference between bridge replacement
costs and the money NYPA will make on the extra electricity? Has the
contractor for damming off the falls already been chosen behind closed
doors? Is this a one hand washes the other deal—or are we being too
cynical and suspicious here? Where do you live?

The Olmsted bridge is part of our cultural and
historical heritage. The NYS Office of Parks, Recreation and Historic
Preservation has a mandate, indicated by its name, to preserve such
artifacts. If the stones of the bridge need to be dismantled one by one
after being photographed and numbered, and then reassembled so that the
original bridge can be preserved, restored to a safe condition and
used for the purpose originally intended, then that is what needs to be
done.

But what we are getting instead is an OPRHP
spokesperson and others on TV news saying how “neat,” or words to that
effect, it will be for people to see the falls shut off again, second time
in so many years, etc, etc. We question how “neat” it will be for the
mother and father in Europe, India, China, or elsewhere in the world, who
skip lunch for twelve years to save money to bring their family to Niagara
Falls, when they arrive during the shut-off year.

If it’s so neat, why not install a dam at the
east end of Goat Island that can be easily opened and closed so that the
water flowing to the American Falls can be shut off for a week or two
every tourist season? The shut off time could be marketed to extend the
season, promoted as the “Niagara Shutdown Festival.” Rates in OPRHP
parking lots could be doubled during those weeks and State Park gift and
souvenir shops could do a brisk business selling tee-shirts with “I was at
the Niagara Shutdown Festival! It was Neat!” printed on them.

I hesitated to mention this idea because
someone in OPRHP might take it seriously. And I’m not kidding. Are you
still wondering why we’re endorsing a Federal Commission Management
entity?

Other Remarks on the NNHAS

1). Restoration should be given consideration
equal to preservation. The Niagara Frontier should be able to reclaim some
of what it has lost.

2). The Whirlpool Jet Boat Tours in the lower
Niagara is mentioned as if it’s an asset, as if it doesn’t detract from
the experience of the natural world at Niagara. Has an Environmental
Impact Study been done re this enterprise?

3). No significant “attractive glimpses” of
the lower gorge can be had from “scenic drives” on the Robert Moses
Parkway. (OPRHP cites these “attractive glimpses” as rationale for parkway
retention). NHP has a video shot from a car window that supports the
assertion of no significant “glimpses.”

4. Somewhere in “tourism theme” (p. 38) or
elsewhere there should be a recognition of drama (plays) painting,
sketches, drawings, music, poetry, novels, books of nonfiction, historical
studies, essays, and film in the “memorabilia that human ingenuity created
in order to interpret an overpowering natural feature.”

5). The study report repeatedly mentions the
44 million dollars spent in the region by OPRHP as if the mere expenditure
of large amounts is praiseworthy. But over half of that money went to
retrofit the Niagara Reservation Observation Tower, which Gov. Pataki
initially called an “eyesore,” saying “it had to go,” to be replaced by
underground elevator access to the Maid of the Mist boat landing. Instead,
the tower was shortened and we ended up with two thirds of an eyesore,
plus a huge, new, concrete gift shop in Prospect Park, further removing us
from the Olmsted vision. Nearly another 3 million was spent on the
overwide “people movers” that resulted in additional blacktop on Goat
Island. Yet, OPRHP continues their great silence about their three to
four acre maintenance garage property on the gorge rim. Perhaps they
are secretly working to remove it as a contribution to the greenway and
there will be an announcement soon.

{A} NYPA wasn’t too keen on exploring some of
these opportunities during relicensing. They refused to discuss the
parkway removal issue and the damage done to the gorge wall and Devil’s
Hole State Park by their access road, created by easement agreement with
OPRHP. They hired consultants to do their own study of the parkway issue;
the results did not offend their sister agency, OPRHP. The access road
issue was put off repeatedly until they were able to defer it and the
problematic details of other environmental issues to the newly created
greenway subsidiaries, who will receive settlement money from them,
including OPRHP and the Greenway Commission.

{B} They stonewalled the security issue:
(“We’re prepared for any contingency” and it couldn’t be discussed since
it’s a matter of Homeland Security.) NHP attempted to alert our homeland
security and political representatives to what we considered a security
risk for the main generating plant. See attached summary.

Repeated, personal, and pointed requests, in
writing and by phone, to both Senator Schumer and Congresswoman Slaughter
(among others) for responses to our concerns, we regret to report,
resulted in no responses whatsoever.

Concluding Remarks

NHP does not have the status or power of a
state agency or authority. We don’t have politicians “on our side.” We
don’t have lots of money. We’re not camera friendly. What we do have is a
genuine concern for the natural environment at Niagara, and a rational,
compelling argument for parkway removal and natural landscape restoration,
incorporating economic benefits for the region. We believe we have
successfully refuted every objection of those who wish to retain all or
part of the parkway, over and over, since the same tired complaints keep
being repeated as if they have merit. The proposal for the removal of all
four lanes of the gorge parkway has the endorsement of 67 organizations
with a combined membership of over a million, and about 4,000 individuals
also in favor. (List of organizations attached.)

We don’t mention this thinking it will change
anything. We recognize that public policy is not often formulated based on
rational argument. Who’s boss is much more important, along with who’s got
the money. So when OPRHP announces the closed parkway lanes will be a
“recreationway” (p 16) we know that was the plan from the beginning, that
there never was a real “pilot,” which we said from the beginning. (see
Pilot Project Response attached)

We put this in writing so it will be part of
our region’s historical record. The “recreationway” may eventually be a
road for people movers next to the commuter route lanes (with portable
food shacks scattered along the way)— and what could have been a restored
slice of wilderness extending from the state’s most unique and well known
gorge and river will continue to be degraded for the people-mover money,
minor political considerations and personal convenience. Castro will move
on to another job, and fifty or a hundred years from now, people will look
back and the issue might be seen differently, even by those in a position
of power.

Please don’t conclude from the reality-based
speculation of the last few sentences that we’re opting out of future
debate about Niagara’s natural environment. We trust that a Federal
Commission will see more clearly than others some of what needs to be
done.